Administration of Non VA-Funded Research Grants

1. Purpose

To define procedures governing the relationship between the Veterans Affairs Health Care System (VAXXX) and the NAME OF NPC (NPC), established under 38 USC 7361-7368, whose purpose is to manage and administer research and education programs funded by non-VA monies.

2. Background

Prior to 1987, research funds from non-VA (Department of Veterans Affairs) sources had been administered via accounts administered by the University of YYYY or by accounts administered by VA General Post Funds.  Recognizing that a more effective mechanism was necessary for the administration of non-VA research and education funds, Congress enacted 38 USC 7361-7368 which authorizes and describes a mechanism whereby funds not appropriated by Congress to the VA may be received and administered by a nonprofit corporation at any VA medical center established in accordance with the terms stated in this law.  In YEAR, the VA XXX formed the NPC.

3. Policy

1. In order to achieve the purposes of 38 USC 7361-7368, it will be the policy of the VA XXX that all Federal, State, Corporate, Foundation and private charitable awards and donations that are received to support research activities will be managed and administered by NPC when performance of the work pursuant to the research occurs on VA premises (e.g. laboratory and office space, computer hardware, subject acquisition and testing and database research).  Awards and donations related to work performed entirely on University premises may be administered by the University with subcontracts covering costs incurred at the VA XXX.  The performance criterion relates to where the work is actually done (e.g. laboratory space, office space, subject acquisition and testing, computer hardware for database research).
2. The Associate Chief of Staff for R&D at the VA XXX will not sign the Request for Extramural Support (RES) form, as required by University Contracts and Grants and by the NIH, for University submitted grants that are not in compliance with the distribution of performance sites defined above.
3. The VA XXX Research and Development Committee will not approve new clinical research studies supported by pharmaceutical companies and other organizations (insert as appropriate: with the exception of federal grants) that are not in compliance with the distribution of performance sites defined above.

4. Effective Date

This policy will become effective on the anniversary date of any existing award after DATE and pertains to all grants and awards except Center grants (e.g. PPGs, SCOR).  These should be discussed well in advance to determine which administrative entity will manage and administer the awards.  Exceptions to this policy will be granted only by written recommendation of the Associate Chief of Staff for R&D and approval by the Director, VA XXX.

5. Biennial Review, Rescission or Reissue Date

Research Service (151) will review this policy for rescission or reissue within two years of the date of issue.

6. References

            38 USC 7361-7368

            Handbook 1200.17

7.Rescissions

            None

            (Signature)
            Director

            Distribution A

Sample VAMC Policy 2

Administration of Non VA-Funded Research Grants

1. Purpose

To define procedures governing the relationship between the Veterans Affairs Health Care System (VAXXX) and the NAME OF NPC (NPC), established under 38 USC 7361-7368, whose purpose is to manage and administer research and education programs funded by non-VA monies.

2. Background

Prior to 1987, research funds from non-VA (Department of Veterans Affairs) sources had been administered via accounts administered by the University of YYYY or by accounts administered by VA General Post Funds.  Recognizing that a more effective mechanism was necessary for the administration of non-VA research and education funds, Congress enacted 38 USC 7361-7368 which authorizes and describes a mechanism whereby funds not appropriated by Congress to the VA may be received and administered by a nonprofit corporation at any VA medical center established in accordance with the terms stated in this law.  In YEAR, the VA XXX formed the NPC.

3. Policy

1. In order to achieve the purposes of 38 USC 7361-7368, it will be the policy of the VA XXX that all Federal, State, Corporate, Foundation and private charitable awards and donations that are received to support research activities will be managed and administered by NPC if more than 50% of performance (e.g. laboratory and office space, computer hardware, subject acquisition and testing and database research) is on VA XXX premises.  Awards and donations with more than 50% of the work performed on University premises may be administered by the University with subcontracts covering costs incurred at the VA XXX.  The fifty percent performance criterion relates to where the work is actually done (e.g. laboratory space, office space, subject acquisition and testing, computer hardware for database research).
2. The Associate Chief of Staff for R&D at the VA XXX will not sign the Request for Extramural Support (RES) form, as required by University Contracts and Grants and by the NIH, for University submitted grants that are not in compliance with the distribution of performance sites defined above.
3. The VA XXX Research and Development Committee will not approve new clinical research studies supported by pharmaceutical companies and other organizations (insert as appropriate: with the exception of federal grants) that are not in compliance with the distribution of performance sites defined above.

4. Effective Date

This policy will become effective on the anniversary date of any existing award after DATE and pertains to all grants and awards except Center grants (e.g. PPGs, SCOR).  These should be discussed well in advance to determine which administrative entity will manage and administer the awards.  Exceptions to this policy will be granted only by written recommendation of the Associate Chief of Staff for R&D and approval by the Director, VA XXX.

5. Biennial Review, Rescission or Reissue Date

Research Service (151) will review this policy for rescission or reissue within two years of the date of issue.

6. References

            38 USC 7361-7368

            Handbook 1200.17

7.Rescissions

            None

            (Signature)
            Director

            Distribution A